Effective Date: September 22, 2026

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At Blueprint Finance, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy. 

These Services are branded as ‘Concrete’ or ‘Glow’ and are made available through the Concrete website(s) (including the informational site at concrete.xyz and the Concrete Foundation site at concretefoundation.xyz (the “Foundation Site”)) and the Concrete application at app.concrete.xyz. The applicable Terms of Use for certain portions of the Services may reference Concrete Foundation or Concrete Network Services Ltd; however, this Privacy Policy is provided by Blueprint Finance (“Blueprint Finance,” “we,” “us,” and “our”), which is responsible for the collection and use of personal data described in this Privacy Policy (including as a “controller,” where applicable). The Foundation Site is primarily informational and also includes functionality through which eligible users may connect a Wallet and claim the Concrete token (“CT”) using third-party technology (the “CT Claim”). Staking CT occurs through a Vault on app.concrete.xyz and is part of the Services.

Concrete Network, Ltd. (“CNL”), a British Virgin Islands company, is responsible for the minting and initial distribution of CT. CNL is the controller of Personal Data processed to determine eligibility for and administer the CT Claim, including Wallet addresses, screening results and claim and transaction data, in each case to the extent processed in connection with the CT Claim. Blueprint Finance is the controller of all other Personal Data described in this Privacy Policy, including Personal Data processed in connection with the Services other than the CT Claim, and is the point of contact for any request or question under this Privacy Policy, including in relation to the CT Claim. Where this Privacy Policy describes processing in connection with the CT Claim, references to “we,” “us” and “our” include CNL.

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Remember that your use of Blueprint Finance’s Services is at all times subject to our Concrete Terms of Use and/or Glow Finance Terms of Use, as applicable, which incorporate this Privacy Policy. Your use of the CT Claim is also subject to the applicable Claim Terms. Any terms we use in this Policy without defining them have the definitions given to them in the Concrete Terms of Use and/or Glow Finance Terms of Use, as applicable, or, in relation to the CT Claim, in the Claim Terms. 

You may print a copy of this Privacy Policy by clicking here.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Blueprint Finance website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Privacy Policy Table of Contents

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that may be collected and/or may have been collected over the past 12 months:

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing, and Improving the Services
  • Creating and managing your account or other user profiles.
  • Processing orders or other transactions; billing.
  • Providing you with the products, services, or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Doing fraud protection, security, and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
• Marketing the Services
  • Marketing and selling the Services.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Blueprint Finance or the Services
• Administering the CT Claim
  
  • Determining whether a Wallet is eligible to claim CT and the applicable allocation.
  • Screening Wallet addresses and IP addresses against sanctions, jurisdictional, fraud and blockchain-risk restrictions, and maintaining records of that screening.
  • Obtaining, generating or validating claim proofs and related transaction data.
  • Processing and recording claims of CT and providing claim-related support.
  • Complying with CNL’s legal and regulatory obligations in connection with the initial distribution of CT.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above-referenced categories of Personal Data may be collected, used, and disclosed to the government, including law enforcement, or other parties to meet certain legal requirements and enforce legal terms, including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as sanctions compliance, preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Blueprint Finance, CNL or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent. 

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you link your Wallet to or otherwise use our interactive tools, the CT Claim or Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.  
  • When you use the Services, such information is collected automatically.
    • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
• Third Parties
  • Vendors
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. Some providers independently determine the purposes and means of Personal Data they collect directly from you, and their own privacy notices apply to that processing.
    • CT claim infrastructure providers (such as Merkl) provide us with eligibility, allocation, claim status, and related claim data associated with your Wallet address.
    • We may use blockchain analytics providers to screen Wallet addresses against sanctions and other eligibility restrictions.
  • Public Blockchains
    
    • We may collect publicly available Wallet and transaction data from blockchain networks in connection with the Services and the CT Claim.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. 

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology, and communication providers.
  • Analytics providers for web traffic or usage of the site.
  • CT claim infrastructure providers (such as Merkl), which process your Wallet address and associated claim data.
  • Blockchain analytics and sanctions screening providers.
  • Wallet connection, blockchain node and similar infrastructure providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
• Business Partners. These parties partner with us in offering various services. They include:
  • Blockchains, foundations, and protocol providers through which the Services are deployed.
  • Token swap aggregators, restaking network providers, automated market makers, money market lenders, and similar providers of integrations or interoperable features with the Services.
  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities.
• Parties You Authorize, Access or Authenticate
  • Third parties you access through the services and any other third parties you authorize us to share your Personal Data with.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is not Personal Data

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.  

Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Please note that:

• The Services, including the informational site at concrete.xyz, the Foundation Site and the Concrete application at app.concrete.xyz, use Cookies as described in this section. These include Essential Cookies, such as Cookies that record your consent preferences, Cookies set by our security and performance providers (such as Cloudflare), and Cookies or similar technologies used by embedded tools such as our customer support widget, and Performance/Analytical Cookies, including Google Analytics on the Foundation Site. When you connect a Wallet for the CT Claim, information about your Wallet connection is stored in your browser; that storage is necessary for the claim functionality to work.
• Because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services, and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services, which may be enabled through our Services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website, and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, where a Cookie management tool is made available, you can access or modify your preferences through that tool. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or the United Kingdom, respectively.

Data Security

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• CT Claim Data (including Wallet address, IP address and screening results) is retained for as long as reasonably necessary to administer and document the initial distribution of CT, comply with legal and sanctions obligations, resolve disputes, and prevent duplicate or fraudulent claims.

• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively, and efficiently.

Personal Data of Children

As noted in the Concrete Terms of Use and the Glow Finance Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at [email protected].

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Liechtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR. “Personal Data generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure. Blueprint Finance will be the controller of your Personal Data processed in connection with the Services other than the CT Claim. CNL is the controller of Personal Data processed in connection with the CT Claim.

Personal Data We Collect

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected]. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data. 

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity:  We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Use or the Claim Terms with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. 
  • Profile or Contact Data
  • Payment Account Identifiers
  • Transaction Data
  • Device/IP and Geolocation Data
  • Other Identifying Information that You Voluntarily Choose to Provide
  • CT Claim Data
• Legitimate Interest:  We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: 
  • Profile or Contact Data
  • Payment Account Identifiers
  • Transaction Data
  • Device/IP and Geolocation Data
  • Web Analytics
  • Other Identifying Information that You Voluntarily Choose to Provide
  • CT Claim Data
  • We may also de-identify or anonymize Personal Data to further our legitimate interests. 
    Examples of these legitimate interests include (as described in more detail above):
  • Providing, customizing, and improving the Services.
  • Corresponding with you.
  • Meeting legal requirements and enforcing legal terms.
  • Completing corporate transactions.
  • Administering and securing the CT Claim and enforcing applicable eligibility restrictions.
• Consent:  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 
• Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties. 

EU, UK, and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.  

• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 
• Erasure:  You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability:  You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection:  You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint:  You have the right to lodge a complaint about Blueprint Finance’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services may be hosted in the United States (“U.S.”) or in other countries through Blueprint Finance and its service providers. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Blueprint Finance and that Blueprint Finance’s primary processing operations take place in the U.S., and you authorize Blueprint Finance to transfer and process your information to and in the U.S. and other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses. Personal Data processed in connection with the CT Claim is processed in the U.S. using infrastructure operated by Blueprint Finance and its service providers.

British Virgin Islands Data Subject Rights (CT Claim Data)

This section applies to Personal Data for which CNL is the controller in connection with the CT Claim, to the extent the British Virgin Islands Data Protection Act, 2021 (the “BVI DPA”) applies to that processing. You have the rights set forth below. For more information about these rights, or to submit a request, please email us at [email protected]; Blueprint Finance will coordinate with CNL as necessary. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.

• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Information:  You can request more information about the purposes for which your Personal Data are processed.
• Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Restriction:  You have the right to restrict the processing of your Personal Data.
• Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such Personal Data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data if such use or disclosure is necessary to enable you to utilize some or all of our Services or the CT Claim.
• Objection:  You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Deletion:  You have the right to require us to delete your Personal Data in some limited circumstances. We cannot alter or delete data recorded on public blockchains.
• Breach Notification:  You have the right to be informed of a breach of your Personal Data (unless the breach is unlikely to be prejudicial to you).
• Right to File Complaint:  You have the right to lodge a complaint about our practices with respect to your Personal Data with the British Virgin Islands Information Commissioner.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• https://concrete.xyz/
• https://concretefoundation.xyz/
• [email protected]